Sms Implementation Guide 2
Sms Implementation Guide 2
For:
Revision 3
June 1, 2010
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Table of Contents
1. PURPOSE..................................................................................................................................3
2. OBJECTIVE..............................................................................................................................3
3. APPLICABILITY.....................................................................................................................4
4. REFERENCES.........................................................................................................................4
5. GUIDANCE DOCUMENTS AND TOOLS............................................................................5
6. SMS PILOT PROJECT............................................................................................................7
7. ROLES, RESPONSIBILITIES, AND RELATIONSHIPS...................................................8
8. LIMITATIONS.......................................................................................................................10
9. SMS IMPLEMENTATION STRATEGY............................................................................11
10. IMPLEMENTATION LEVELS..........................................................................................13
11. ANALYSIS PROCESSES....................................................................................................17
12. IMPLEMENTATION PLAN...............................................................................................18
13. SMS PARTICIPATION VALIDATION PROGRAM......................................................20
14. SMS IMPLEMENTATION PROCESSES.........................................................................22
Appendix 1......................................................................................................................23
Level 1 Expectations......................................................................................................23
Appendix 2......................................................................................................................53
Level 2 Expectations......................................................................................................53
Appendix 3......................................................................................................................62
Level 3 Expectations......................................................................................................62
Appendix 4......................................................................................................................70
Level 4 Expectations......................................................................................................70
Appendix 5......................................................................................................................72
Preliminary Gap Analysis Tool.....................................................................................72
Appendix 6......................................................................................................................81
Detailed Gap Analysis Tool...........................................................................................81
Appendix 7....................................................................................................................155
SMS Assessment Protocol..........................................................................................155
Appendix 8....................................................................................................................157
Cross Reference between AC 120-92 and the SMS Framework.............................157
Appendix 9....................................................................................................................160
Example Letter of Acknowledgement........................................................................160
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1. PURPOSE.
a. This SMS Implementation Guide:
(1) Contains guidance, expectations and procedures necessary to implement a Safety
Management System (SMS) by aviation service providers (air operators, aviation maintenance
organizations, flight training organizations, etc.).
b. This implementation guide is not mandatory and does not constitute a regulation.
Development and implementation of an SMS is, therefore, voluntary. While the Federal Aviation
Administration (FAA) encourages each service provider to develop and implement an SMS, these
systems in no way substitute for regulatory compliance or with other certificate requirements, where
applicable.
2. OBJECTIVE. The overall objective of this implementation guide is to assist a service provider
in developing and implementing an integrated, comprehensive Safety Management System for their
entire organization. Specifically, it will help ensure that a service provider’s SMS will be capable of:
a. Receiving safety input from internal and external sources and integrating that information
into their operational processes;
The implementation guide will also assist FAA Certificate Management Teams (CMTs) in
evaluating organizations’ SMS programs and participating in further development of
implementation and oversight strategies.
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Note: Within the context of this document, the term “FAA Certificate Management Team” or
just plain CMT, refers to any FAA oversight organization, such as an Air Transportation
Oversight System Certificate Management Team (ATOS CMT), Certificate Management
Office (CMO), Certificate Holding District Office (CHDO), Flight Standards District Office
(FSDO) and any other designation that includes FAA Principal Inspectors.
4. REFERENCES. The following references are recommended reading material for users of
this implementation guide in development and implementation of an SMS.
e. FAA Order VS 8000.367, Aviation Safety (AVS) Safety Management System Requirements
g. SMS Framework, FAA, AFS SMS Program Office Safety Management System Framework
h. SMS Assurance Guide, FAA, AFS SMS Program Office Safety Management System
Assurance Guide
i. SMS Guidebook for Developing a Safety Management System for Air Operators (Currently in
development)
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5. GUIDANCE DOCUMENTS AND TOOLS.
a. FAA Guidance. The FAA continues to consider and review a formal SMS rulemaking
effort corresponding to changes made in ICAO Annex 6 as well as the FAA’s own internal System
Safety objectives. The FAA Associate Administrator for Safety issued Order VS 8000.1, Safety
Management System Doctrine, in 2006 (Recently replaced by Order 8000.369, Safety Management
System Guidance). These documents provide a high-level description for SMS implementation across
the National Airspace System.
b. AVS Guidance. FAA Order VS 8000.367, Aviation Safety (AVS) Safety Management
System Requirements was issued in 2008. At Appendix B, Product/Service Provider SMS
Requirements outlines the minimum set of requirements that must be established for constituent
service providers to implement a Safety Management System. At present, however, SMS
implementation by service providers remains voluntary in the United States.
c. SMS Program Office Guidance. Advisory Circular (AC) 120-92 has been the “standard”
for voluntary SMS implementation since 2006. The SMS Program Office (SMS PO) has revised AC
120-92 (AC 120-92A), to bring it in alignment with the current ICAO SMS Framework, to conform to
FAA Order VS 8000.367, and to incorporate improvements based on feedback from users.
NOTE: In the interim, the SMS PO has issued a SMS Framework document, SMS Assurance
Guide and this SMS Implementation Guide, to serve as guidance until AC 120-92A, is
released.
(1) SMS Framework. The SMS PO has developed an SMS Framework document; it
is the current “standard” for voluntary implementation of SMS by service providers. It is
similar in scope and format to the international ISO standards and is modeled after the safety,
quality, and environmental management standards developed by a variety of organizations such
as ISO, the British Standards Institute, Transport Canada, Standards Australia, and the
International Air Transportation Association (IATA). The SMS Framework also incorporates
the current requirements of Annex 6, of the conventions of the International Civil Aviation
Organization (ICAO), the current requirements of FAA Order VS 8000.367, Appendix B, and
is closely aligned with the current ICAO SMS Framework. There are only minor functional
differences between the SMS Framework and Appendix 1 of AC 120-92; however layout,
numbering and formatting have been significantly improved for ease of use.
(2) SMS Assurance Guide. The SMS Program Office has developed an SMS
Assurance Guide as an assessment tool for service providers and CMTs. The SMS Assurance
Guide represents each functional expectation found in the SMS Framework in the form of a
question and is intended to be used during the development and implementation of an SMS by
an organization or by the FAA CMT for oversight guidance. The SMS Assurance Guide is
based entirely on the SMS Framework. Compliance with the SMS Assurance Guide will
insure compliance with the SMS Framework. If differences in interpretation occur, the SMS
Framework will prevail.
NOTE: Until AC 120-92A is released (expected Jul/Aug, 2010), the SMS Framework,
SMS Assurance Guide and this SMS Implementation Guide should serve as guidance
for SMS objectives, expectations and implementation procedures for SMS PP
participants and others desiring voluntary implementation of SMS.
(4) Gap Analysis Processes and Tools. An initial step in developing an SMS is for the
service provider to analyze and assess its existing programs, systems, processes, and activities
with respect to the SMS functional expectations found in the SMS Framework. This process is
called a “gap analysis”; the “gaps” being those elements in the SMS Framework that are not
already being performed by the service provider. Two types of gap analysis processes are
preformed:
(a.) The “Preliminary Gap Analysis” process, performed onsite with the assistance
of the Implementation Support Team (IST, described below), the service provider’s
management and the FAA CMT (consisting of principal inspectors and other inspectors
involved with certificate oversight). The preliminary gap analysis represents an “executive
overview”, a high level subjective analysis of where the service provider stands with respect
to the SMS Framework.
(b.) The “Detailed Gap Analysis” process is a much more in-depth process and is
performed by the service provider (with the involvement of the company’s FAA CMT). It is
a comprehensive and thorough assessment of each program, process and control of the
organization as compared to the objectives and expectations of the SMS Framework.
Depending upon the size and complexity of the organization, the detailed gap analysis may
take 4 to 6 months to complete. The detailed gap analysis is a “living” process and will be
continuously updated as SMS implementation progresses.
NOTE: Both the preliminary and detailed gap analysis processes cover all areas of
company operations and all elements of the SMS Framework.
d. Assessment Tools. During early 2009, industry user feedback indicated considerable
difficulty in completing the gap analysis with the original Safety Attribute Inspection (SAI) design
assessment tools. For this reason, a new set of Preliminary and Detailed Gap Analysis Tools has been
completed to serve in the interim while the SAI design assessment tools are revised. The purpose of
these interim tools is to convey the expectations of the SMS Framework in a user-friendly format; as
such they are spreadsheets that contain the same questions found in the SMS Assurance Guide. The
SMS Assurance Guide is based on the SMS Framework and the 6 system attributes developed for the
Air Transportation Oversight System (ATOS) and are now part of ICAO recommended practices.
Additional room for the inclusion of source document references and progress/status by company
divisions is provided in these tools. The titles of company divisions at the top of the gap analysis tools
may be customized to fit the individual structural of the service provider.
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If conflicts between the language in the gap analysis tools and the SMS Framework are found, the
language in the SMS Framework should prevail. The key objective of the gap analysis is to determine
whether or not existing programs or processes in the company meet the expectations delineated in the
SMS Framework, so this objective should be kept in mind throughout the gap analysis and planning
process.
6. SMS PILOT PROJECT (SMS PP). In 2007, the FAA initiated the SMSPP for service
providers desiring to voluntarily develop SMS programs. SMS PP studies are conducted to track and
evaluate multiple data-point results, as well as to provide service providers with a means of developing
and implementing their SMS under FAA mentorship.
(5) What are the pros & cons of implementing an SMS in a particular operational
department first, vs. implementing across an entire company’s operational sphere
simultaneously?
b. Not Rule Making. It is important to note that the SMS PP effort focuses on three areas; 1)
implementation strategies; 2) oversight interfaces; and 3) to gain experience for both the FAA and
service providers, but NOT to develop Federal Aviation Regulations (FARs) or rules. There is an
on-going rule-making project, separate from the Pilot Project, which is considering SMS regulatory
requirements. While Pilot Project objectives do not include the development of regulations, they
certainly solicit and encourage feedback, input, best practices and lessons learned from both an
Industry perspective, as well as from a regulator perspective, which will be considered and possibly
incorporated into future guidance material.
c. SMS Focus Group. Originally formed by the FAA in 2003, the Safety Management System
Focus Group (SMSFG) was developed after Joint Project Development Organization (JPDO)
development of an “SMS Template” for SMS Standards. The SMSFG was reconstituted in 2007, as a
consortium of aviation industry and FAA representatives, who meet periodically to provide two-way
communication between the SMS PO and participants in SMS PP, and others involved in voluntary
SMS implementation. The SMSFG also provides a unique forum for knowledge sharing among
participants. The SMSFG meets twice a year and is hosted by the SMS PO.
d. SMS PP Participants. Service providers of varying types, size and complexity are working
with the FAA in voluntary SMS Implementation Pilot Projects. As of May 2010, more than 90, FAR
Part 121, FAR Part 135 Operators, Part 141/142 organizations and Part 145 Repair Stations are
participating at various levels and phases of voluntary SMS implementation. The service provider
organizations, SMS Implementation Support Team (IST) and the respective certificate oversight
organizations (CHDO, FSDO, CMT, CMO, etc), are involved throughout the entire SMS
implementation process.
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a. Flight Standards SMS Program Office (SMS PO). FAA Order FS 1100.1A (dated
9/28/08) Flight Standards Service Organizational Handbook identifies the responsibilities of the SMS
PO.
(1) The SMS PO provides policy and guidance on Flight Standards internally and
externally oriented SMS requirements and interfaces, provides support to the AFS Director,
Deputy Director, and Executive Steering Committee in execution of the AFS SMS doctrine,
provides direction, guidance, and coordination with headquarters and field divisions in
development of SMS policies, procedures and work instructions, and is responsible for SMS
standardization and development of training requirements.
(a.) Focal point for AFS in future SMS-related rulemaking and policy
development efforts;
mentorship of SMS
related FAA Academy training;
and
orientation materials for SMS; and
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Team (IST) to assist field organizations and service providers in
development and implementation of voluntary and mandatory external SMS
programs.
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b. Aviation Service Provider Organizations. The SMS Framework provides guidance for an
service provider to develop and document its SMS on a voluntary basis. A separate SMS manual is not
required, however many service providers find a separate manual useful. The SMS may be
documented in a form and manner that best serves the service providers need, however, any
modifications of existing FAA approved/accepted programs and their associated documents must be
coordinated with the appropriate FAA oversight organization. Safety policies developed by service
providers’ top management will be clearly communicated throughout the entire organization. Safety
Risk Management (SRM) and Safety Assurance (SA) programs will be developed and maintained.
Safety Promotion (SP) activities will take place to instill or reinforce a positive safety culture
throughout the organization.
c. Implementation Support Team (IST). Formed and managed by the SMS PO, the SMS IST
is comprised of selected SMS PO personnel, FAA Regional Representatives, AFS 900 Field Support
Team Members, FAASTeam Members, FAA Headquarters and field personnel. The purpose of the
IST is to provide assistance, as requested, to the service provider and its oversight organization
throughout the SMS development period. This assistance will be limited to guidance related to the
development and implementation of the SMS, and may include briefings, orientation sessions,
meetings and/or seminars, as required. SMS IST members will not be involved in oversight of the
service provider and will not perform inspections, audits or evaluations of the service provider.
(a.) Provide assistance, as requested, to the service provider and its oversight
organization throughout the Pilot Project period;
(b.) Participate in meetings with the service provider and its oversight
organization, if requested;
(c.) Review the service provider’s implementation plan and other documents
and provide objective input;
(d.) Discuss the requirements of exit criteria for all maturity phases of SMS
implementation with the service provider and its oversight organization;
(e.) Receive pilot project inputs from both the service provider and oversight
organization; and
d. Oversight Organization. The FAA office (CMO, CMT, CHDO, FSDO, etc.) that normally
provides regulatory safety oversight of the service provider will be referred to as the “oversight
organization” or the CMT and will continue all of its normal oversight and certificate management
duties. As organizations develop their SMS, a natural interaction between the safety management
efforts of the oversight organization and those of the service provider will develop. This relationship
can leverage the efforts of both parties to provide a more effective, efficient, and proactive approach to
meeting safety requirements while at the same time increasing the flexibility of the service provider to
tailor their safety management efforts to their individual business models.
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(1) In order to fully understand the service provider’s approach to SMS, it is important
for the oversight organization to be fully engaged during SMS development and
implementation. Collaboration with the service provider’s SMS development will also provide
the oversight organization with an opportunity to gain experience in oversight of the SMS, as
well as using SMS as a tool for interfacing with the service provider’s management.
Note: An aviation service provider will not be accepted into the SMS Pilot Project
without participation of their respective FAA oversight organization.
(2) The oversight organization will be responsible for participating in the development
process meetings and gap analysis’s including the Initial Workshop (described in Appendix 1)
meeting and the presentation of an implementation plan by the service provider. The oversight
organization will also be responsible for reviewing the service provider’s implementation plan
and its accomplishment at each maturity level of the SMS implementation.
(c.) Review the service provider’s implementation plan and other documents;
(d.) Discuss the requirements of the exit criteria for all phases with the
service
provider’s and the IST; and
Note: Neither FAA oversight organizations (CMT, FSDO, etc) nor the SMS PO are currently
authorized to approve or accept SMS programs. This includes acceptance of any part, process
or element of an SMS though inclusion in FAA approved/accepted documents such as
operator/agency manuals (e.g. GOM, GMM, etc.). FAA Notice 8900.SMS will address this
issue when it is published (expected Jul/Aug, 2010).
8. LIMITATIONS. The SMS in no way substitutes for regulatory compliance with any
certificate requirements, where applicable. There are no new regulatory programs introduced.
a. Aviation Safety Action Program (ASAP) and Internal Evaluation Programs (IEP). The
FAA is seeking to increase the use of current voluntary programs in the process of safety management,
particularly use of the ASAPs and IEPs. Both of these programs have strong relationships to the
functions of safety assurance and safety promotion in an SMS. Service providers are encouraged to
consider integrating these programs, through existing processes, into a comprehensive approach to
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SMS.
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b. Enforcement Incentives. Service providers and their employees should be aware that, at
present, the SMS and/or participation in the SMS PP and/or voluntary SMS development can not
provide enforcement “incentives” that are outside provisions of existing FAA programs (e.g. ASAP,
VDRP, ASRS). Additionally, it should be noted that certain aspects of the final SMS rule, if and
when issued, may differ from those used in the voluntary implementation program. It is however, the
objective of the Flight Standards Service to maintain the voluntary implementation and oversight
processes in such a manner as to facilitate the smoothest transition from voluntary to required SMS
programs, should they be required by regulations in the future.
Note: The FAA’s approach to a phased implementation of a SMS is based upon, but slightly
different than the ICAO implementation strategy expressed in ICAO Document 9859, Safety
Management Manual (SMM), Chapter 10, Appendixes 1 and 2 (Gantt Charts).
(1) In the development and implementation of a SMS it is best to break down the
overall complexity of the task into smaller, more manageable subcomponents. In this way,
overwhelming and sometimes confusing complexity, and its underlying workload, may be
turned into simpler and more transparent subsets of activities that only require minor increases
in workloads and resources. This partial allocation of resources may be more commensurate
with the requirements of each activity as well as the resources available to the service provider.
(2) The reasons that justify why a phased approach to SMS implementation is
recommended can be expressed as; (a) providing a manageable series of steps to follow in
implementing an SMS, including allocation of resources; and (b) effectively managing the
workload associated with SMS implementation. (c) a third reason, quite distinct from the
previous two, but equally important, is avoiding “cosmetic compliance”. A service provider
should set as its objective the realistic implementation of a comprehensive and effective SMS,
not the tokens of it. You simply cannot “buy” an SMS system or manual and expect the
benefits of a fully implemented SMS.
(3) Feedback from Pilot Project participants has shown that while full SMS
implementation will certainly take longer, the robustness of the resulting SMS will be enhanced
and early benefits realized as each implementation phase is completed. In this way, simpler
safety management processes are established and benefits realized before moving on to
processes of greater complexity. This is especially true with regard to Safety Risk
Management (SRM). In the reactive phase (Level 2), a service provider will build an SRM
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system around known hazards which are already identified. This allows company resources to
be focused on developing risk analysis, assessment and control processes (that frequently
resolve old long term issues and hazards) unencumbered by the complexities necessary at the
proactive (Level 3) and predictive phases (Level 4).
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10. IMPLEMENTATION LEVELS. The overall objective of the levels is to “…develop and
implement an integrated, comprehensive SMS for [the] entire organization.”
Continuous Improvement 4
3 Proactive
Processes
2 Reactive
Processes
1 Planning &
Organizat ion
0 Orientatio n &
Commit ment
a. Implementation Level Zero: Orientation & Commitment. Level zero is not so much a
level as a status. It indicates that the service provider has not started formal SMS development or
implementation and includes the time period between a service provider’s first request for information
from the FAA on SMS implementation and when the service provider’s top management commits to
implementing an SMS.
(1) Level zero is a time for the service provider to gather information, evaluate
corporate goals and objectives and determine the viability of committing resources to an SMS
implementation effort. Information requested from the FAA may be satisfied with emailed
documents and/or reference material and/or referrals to Internet web sites
(www.faa.gov/about/initiatives/sms) where information/documents/tools may be downloaded.
(2) Face-to face informational meetings between the individual service provider,
responsible FAA CMT and the SMS PO are not normally conducted at level zero; however
they may be conducted on a case-by-case basis depending upon FAA SMS PO resource
availability and other circumstances.
(3) In lieu of individual meetings, activities such as group outreach presentations and
group seminars will be conducted in order to establish relationships and define SMS PP
expectations for service provider’s top management and oversight organizations.
b. Implementation Level One: Planning and Organization. Level 1 begins when a service
provider’s top management commits to providing the resources necessary for full implementation of
SMS through out the organization.
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(1) Gap Analysis. The first step in developing an SMS is for the service provider to
analyze its existing programs, systems, and activities with respect to the SMS functional
expectations found in the SMS Framework. This analysis is a process and is called a “gap
analysis,” the “gaps” being those elements in the SMS Framework that are not already being
performed by the service provider.
(a.) The Gap Analyses process should consider and encompass the entire
organization (e.g., functions, processes, organizational departments, etc.) to
be covered by the SMS. As a minimum, the gap analysis and SMS should
cover all of the expectations of the SMS Framework, Component 1.0 b (1)
(a) or (b), as appropriate.
(b.) The gap analysis should be continuously be updated as the service provider
progresses through the SMS implementation process. A detailed discussion
and a set of tools are available in Appendixes 1, 5 and 6, to assist the service
provider in conducting both the preliminary and detailed gap analysis
process activities.
(2) Implementation Plan. Once the gap analysis has been performed, an
implementation plan is prepared. The implementation plan is simply a “road map” describing
how the service provider intends to close the existing gaps by meeting the objectives and
expectations in the SMS Framework.
(a.) While no actual development activities are expected during level one,
beyond those listed in the SMS Framework, Elements 1.1, 1.2 (partial), 1.3
and 4.1.1 (partial), the service provider organizes resources, assigns
responsibilities, sets schedules and defines objectives necessary to address
all gaps identified.
c. Implementation Level Two: Reactive Process, Basic Risk Management. At level two,
the service provider develops and implements a basic SRM process and plan, organize and prepare the
organization for further SMS development. Information acquisition, processing, and analysis functions
are implemented and a tracking system for risk control and corrective actions are established. At this
phase, the service provider corrects known deficiencies in safety management practices and operational
processes and develops an awareness of hazards and responds with appropriate systematic application
of preventative or corrective actions. This allows the service provider to react to unwanted events and
problems as they occur and develop appropriate remedial action. For this reason, this level is termed
“reactive.” This will include complying with the expectations in Appendix 2. While this is not the
final objective of an SMS, it is an important step in the evolution of safety management capabilities.
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changes to operational processes. The activities involved in the SRM process involve careful analysis
of systems and tasks involved; identification of potential hazards in these functions, and development
of risk controls. The risk management process developed at level two is used to analyze, document,
and track these activities. Because the service provider is now using the processes to look ahead, this
level is termed “proactive.” At this level, however, these proactive processes have been implemented
but their performance has not yet been proven.
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SMS Development Chart
Components, Elements and Processes should be completed Implementation
by the indicated Level of Implementation Level
(*3) Level 2 - Implementation of 2.0 B) 2) a), b) & d) and 3.2, will be limited in level 2
by the lack of the system/task analysis process (process 2.1.1)
Figure 2
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11. ANALYSIS PROCESSES. Guidance and tools have been developed for use in directing
and evaluating progress though the SMS implementation process. These tools are based on
performance objectives and design expectations developed for each Component, Element and Process
of the SMS Framework.
a. System Description and Analysis. Prior to performing the preliminary gap analysis
process, the IST team will assist the company and their CMT in conducting a System Description and
Analysis of the company’s operational functions.
(1) System Description and Analysis. Every system contains inherent potential safety
vulnerabilities which are characterized in terms of hazards. The boundaries of the system, as
per its formal description, must therefore be sufficiently wide to encompass all possible hazards
that the system could confront or generate.
(2) Safety Consequences. The potential for loss or degradation of the system will be
determined, in part, by the characteristics of the operational environment in which the system
will be operated. The description of the environment should therefore, include any factors that
could have a significant effect on safety. These factors will vary from one service provider to
another. They could include, for example, geographic operational locations, owned vs. leased
equipment and facilities, contractor relationships and/or union representation.
(3) Preparatory Briefings. After conducting these briefings the IST team will
facilitate the System Description and Analysis activities. At the completion of the System
Analysis, the preliminary gap analysis process will be conducted.
b. Preliminary Gap Analysis. The objectives of the preliminary gap analysis process are to:
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A more detailed discussion of the Preliminary Gap Analysis Tool is in Appendix 1. The Preliminary
Gap Analysis Tool is in Appendix 5.
c. Detailed Gap Analysis. As stated earlier, the detailed gap analysis process is a
comprehensive, detailed assessment of each element and function of the organization’s systems as
compared to the objectives and expectations of the SMS Framework. The detailed gap analysis
process is performed on a schedule determined by the service provider. Involvement of CMT members
during the process is highly encouraged. The detailed gap analysis will be used to fully assess all parts
of the SMS Framework in comparison to existing programs and processes at the company.
(2) Because SMS is currently voluntary, it is important to note that if certain SMS
expectations are not met, this is not a “deficiency.” The purpose of the gap analysis is to
supplement the development of a comprehensive implementation plan. At the conclusion of the
detailed gap analysis, the results should be summarized at the component/element/process level
to facilitate more efficient implementation planning.
(3) The detailed gap analysis should be continuously updated as the company
progresses through SMS implementation.
(4) The detailed gap analysis process is described in detail in Appendix 1 and the
Detailed Gap Analysis Tool, is in Appendix 6.
d. Summary Gap Analysis Tool. The summary gap analysis is not a separate analysis but is a
summary of the results of the detailed gap analysis. The same tool that was used for the preliminary
gap analysis may used for the summary gap analysis. During or at the end of the detailed gap analysis
activity, the results may be summarized as the summary gap analysis at the component/ element/
process level and this summary may then be used by top management to track SMS implementation.
12. IMPLEMENTATION PLAN. Based on the results of the detailed gap analysis process, an
implementation plan is prepared to “fill the gaps”, the “gaps” being those elements in the SMS
Framework that have not completely met expectations (e.g., are not already being performed) by the
service provider. The SMS implementation plan is a realistic strategy for the implementation of an
SMS that will meet the service provider’s safety objectives while supporting effective and efficient
delivery of services. It describes how the service provider will achieve its corporate safety objectives
and how it will meet any new or revised safety requirements, regulatory or otherwise.
a. Scope and Objective of the Plan. The implementation plan need not be complex or
excessively detailed, but should provide a basic roadmap to meet the overall objective stated in the
SMS Framework to, “…develop and implement an integrated, comprehensive SMS for [the] entire
organization.”
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(1) The SMS implementation plan, which may consist of more than one document, details
the actions to be taken, by whom and within what time-frame. The implementation plan can be
created in any format that is useful to the company but should provide at least the following:
(2) The implementation plan should also span the entire SMS development process. It
should start at preparation and organization, and continue through all levels of maturity. It
should be updated as necessary (along with the detailed gap analysis) as the projects progress.
At each level, top management’s approval of the implementation plan must include allocation
of necessary resources IAW element 1.2 b (2).
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NOTE: Participation in the SMS PP and the issuance of Letters of Acknowledgement do not
constitute formal acceptance or approval of individual SMS programs.
c. Levels of Participation. Three levels of participation are specified for this validation
program. Each service provider may develop their SMS in a modular fashion across their departments
or across the functions of their organizations; however, attainment of the levels shown below are based
on a comprehensive system covering all of the systems listed in Component 1.0, b, (1), (a) or (b) of the
SMS Framework. The overall objective is to develop a comprehensive SMS covering the entire
organization.
(1) SMS Level One: Commitment, Planning and Organization. This level will be
validated when an service provider demonstrates that they have successfully conducted a thorough
preliminary and detailed gap analysis, implemented the processes corresponding to level one of this
SMS Implementation Guide, Appendix 1, developed a comprehensive implementation plan and
presented it to the IST and the CMT. While no actual development activities are expected during this
level, beyond those listed in the SMS Framework, Elements 1.1, 1.2 (partial), 1.3 and 4.1.1 (partial),
the service provider commits resources, assigns responsibilities, sets schedules and defines objectives
in their implementation plan necessary to comply with all expectations of the SMS Framework.
(2) SMS Level Two: Reactive Process, Basic Risk Management. This level will be
validated when a service provider demonstrates that they have successfully implemented the processes
corresponding to level two of this SMS Implementation Guide, Appendix 2, as determined by the
CMT, and assisted by the STAT. At this level, all of the processes of the SMS have been designed and
implemented in accordance with the SMS Framework; however they are only working in a reactive
capacity. Sufficient data has not yet been accumulated at this point to enable proactive analysis.
(3) SMS Level Three: Proactive Processes, Looking Ahead. This level will be
validated when an service provider demonstrates that they have successfully implemented the
processes corresponding with level three of this SMS Implementation Guide, Appendix 3, and that the
performance of these processes has been demonstrated in a performance review conducted by the
CMT, assisted, as necessary, by members of the STAT. At this level, the service provider is
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considered to have a fully instituted SMS, however due to their relative newness the performance and
effectiveness of the SMS processes have not yet been validated for continued system effectiveness.
Safety Policy;
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Updated SMS Training Plan for all employees.
(3) Recommendation Package and Endorsement. The IST Lead will forward the
POC’s recommendation package, along with appropriate endorsement, to the Manager, SMS Program
Office, for review and concurrence.
(4) Recommendation Package Progression. The Manager, SMS Program Office will
forward successful recommendation packages and an unsigned Letter of Acknowledgement to the
Director, Flight Standards Service for approval and signature. Unsuccessful recommendations will be
returned to the IST Lead for appropriate action.
h. APPENDIX 8 – Cross Reference between AC 120-92, App 1 and the FAA SMS
Framework
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SMS Implementation Guide - Appendix 1 - Level 1
Appendix 1
Level 1 Expectations
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
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SMS Implementation Guide - Appendix 1 - Level 1
SMS Implementation Guide
APPENDIX 1
NOTE: Some discussion and guidance from the SMS Implementation Guide is reproduced here, so that
this Appendix may be used as a stand-alone document.
Level 1 Activities: To plan, organize and prepare the service provider for SMS development. These
include:
Top management commitment to implement SMS, define safety policy and convey safety
expectations and objectives to its employees (SMS Framework Element 1.1; “Safety Policy“);
Top management commitment to insure adequate resources are available to implement SMS (in
accordance with SMS Framework Element 1.2 b (2);
Designating a management official who will be responsible for SMS development (SMS
Framework Element 1.3; “Key Safety Personnel“);
Defining safety-related positions for those who will participate in SMS development and
implementation (in accordance with SMS Framework Element 1.2 b (3);
Completing a preliminary and detailed gap analysis on the entire organization for all elements
of the SMS Framework (SMS Implementation Guide, Paragraphs 5, 8 & 9, above);
Comprehensive SMS Implementation Plan addressing implementation of all design
expectations of the SMS Framework (outlined in the SMS Assurance Guide and listed in the
Detailed Gap Analysis Tool) for the entire organization; and
Identifying safety competencies necessary (In accordance with SMS Framework Element 4.1.1
b (1), addressing identified training competency needs in a training plan covering each phase of
development.
Level 1 Input: The decision of an service provider’s top management team to commit to voluntary
implementation of SMS throughout the organization and participation in the SMS Pilot Project (SMS
PP) begins the SMS Level 1 implementation process. Initial contact and coordination with the service
provider’s FAA oversight organization, i.e. Certificate Management Team (CMT), Flight Standards
District Office (FSDO), etc., and the AFS SMS Program Office (SMS PO) will provide the necessary
input of guidance, objectives and expectations for Level 1 Implementation efforts.
References:
SMS Framework, as revised;
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SMS Implementation Guide - Appendix 1 - Level 1
SMS Assurance Guide, as revised; and
SMS Implementation Guide, as revised.
Option 2 is for a service provider that already has an SMS that meets the requirements of one
or more of the levels of implementation.
Steps 1 through 11 guidance material are the same for Option 1 and Option 2. All steps for both
Options are necessary for successful base-lining and standardization of objectives and expectations of
the service provider and their oversight organization. Depending upon the background, experience and
maturity level of the service provider, some steps may be abbreviated, but none may be omitted.
Option 2 procedures will follow below Option 1 procedures and will be enclosed within a text “Box”.
An example of Option 2 procedures is shown at Figure 1, below.
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SMS Implementation Guide - Appendix 1 - Level 1
confront or generate. In particular, it is important that the description includes the interfaces both
within the system, as well as the interfaces with the larger systems of which the system being analyzed
is a part.
The emphasis is on gaining an understanding of how the service provider is structured and identifying
factors that may be considerations when doing the gap analysis, who needs to be involved, how the gap
analysis process itself will be organized, etc.
Additionally, if some parts of the service provider are unionized, there maybe an impact on an
employee reporting system.
If contractors are used for major functions, that must be taken into account, especially if multiple
organizations/vendors are used for the same function.
Distribution of the service provider’s facilities over a large geographic area may have significant
impact on organizational interfaces.
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SMS Implementation Guide - Appendix 1 - Level 1
The first type of analysis is a Preliminary Gap Analysis process and is utilized during the
Initial Workshop phase (Orientation Session), described later in this document. It provides a
high level assessment, or “off the top of the head” judgment by company officials (including
discussion with the CMT and IST members) to get an initial indication of where the company
stands with respect to the SMS Framework expectations.
The preliminary gap analysis also provides an opportunity for discussion, with IST support, of
how each element applies to the particular service provider.
The preliminary gap analysis is accomplished at the “Performance Objective” level for each
component, element and process contained within the SMS Framework.
It is recommended that the Preliminary Gap Analysis Tool (contained in Appendix 5 of this
implementation guide) be used to record this activity; however the company may elect to use
another tool that captures all of the expected material.
During the detailed gap analysis, it is necessary to fully assess all company organizational and
functional areas and all elements contained within the SMS Framework in order to develop a
comprehensive implementation plan. However, it does not entail actual development of any of
the elements during level one beyond those listed in the SMS Framework, Elements 1.1, 1.2
(partial), 1.3 and 4.1.1 (partial). The purpose of the detailed gap analysis is to determine what is
already in place and to provide a basis for further implementation planning.
For those elements of the SMS Framework that are deemed to have been already developed,
the company should provide objective evidence of their accomplishment. Objective evidence
may take the form of physical or electronic documents, manual references, training material,
records, interviews, observations, correspondence (email, memo, etc.), organizational charts,
meeting minutes, etc.
The Detailed Gap Analysis Tool in Appendix 6 may be used to summarize the results of the
detailed gap analysis and to record objective evidence; however the company may elect their
own method of recording.
The Detailed Gap Analysis Tool is a spreadsheet that converts the SMS Assurance Guide into
simple electronic or printed-paper forms to assist in the analysis of all functional expectations
of a SMS. A completed Detailed Gap Analysis Tool will reveal organizational status on all of
the components, elements and processes of the SMS Assurance Guide and therefore, the SMS
Framework.
Gap analyses (preliminary & detailed) should cover the entire set of functions, processes, and
organizational departments in the service provider to be covered by the SMS. As a minimum, the Gap
Analyses should cover all of the operational processes listed in the SMS Framework, Component 1.0 b
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SMS Implementation Guide - Appendix 1 - Level 1
(1) (a) or (b), as appropriate. The Detailed Gap Analyses should be continuously updated as the service
provider progresses through the SMS implementation process.
The gap analysis tools (and the SMS Assurance Guide) contain references to both the current SMS
Framework (new “standard”) and the published Appendix 1, AC 120-92 (old “standard”), to assist
those service providers who began SMS implementation with the old tools and wish to bridge to the
new tools.
The MITRE Corporation, a Federally-Funded Research and Development Corporation (FFRDC) have
been contracted to conduct a set of studies and analysis on the SMS development and implementation
process. MITRE analysts visit selected voluntary implementation sites to collect data on the gap
analysis, planning, and implementation processes. Information collected will be at the discretion of the
company.
Implementation Plan
Once the gap analyses have been performed, an implementation plan is prepared. The implementation
plan is simply a “road map” of how the service provider intends to narrow the existing gaps to meet the
objectives and expectations in the SMS Framework. The SMS implementation plan is a definition of
the approach the service provider will adopt for managing safety. As such, it becomes a realistic
strategy for the implementation of an SMS that will meet the service provider’s safety objectives while
supporting effective and efficient delivery of services. It describes how a service provider will achieve
its corporate safety objectives and how it will meet any new or revised safety requirements, regulatory
or otherwise. Significant items in the plan will normally be included in the service provider business
plan.
As stated above, no actual development activities are expected during level one, beyond those listed in
the SMS Framework, Elements 1.1, 1.2 (partial), 1.3 and 4.1.1 (partial). The implementation plan
should cover all elements of the framework across all of the operational processes of the company (e.g.
flight operations, ground operations, operational control, maintenance, etc.) for all levels of
development (i.e. implementation levels 1-4).
It should be noted that at each level of implementation, top management’s approval of the
implementation plan must include allocation of necessary resources IAW element 1.2 b (2).
Depending on the size and complexity of the service provider,, the SMS implementation plan may be
developed by one person, or by a planning group with an appropriate experience base. Active,
personal participation of all levels of management that are responsible for operational processes will be
essential for a successful SMS. For this reason, participation of these managers in the planning process
is strongly encouraged.
The service provider’s SMS planning group should meet regularly with top management to assess
progress of the implementation plan, and receive resources commensurate with the task at hand.
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SMS Implementation Guide - Appendix 1 - Level 1
Detailed Procedures: Option 1 (Service providers Initial SMS)
The “Flow Diagram of Level 1 Activities” at Figure 2 outlines detailed guidance for Level 1, Option 1,
activities. Each activity in the process is represented as a step that corresponds with the flow diagram
box numbers. Option 2 activities will be shown in a “text box” following the Option 1 procedures.
2. Contact CHDO Mgt 7. Orientation: SMS 11. Detail Gap Analysis 15. Present Implementation
Concepts
Plan
3. Initial 8.
Coordination 12.
16. Validation of Gap Analysis/ Implementatio
FamiliarizationComprehensive Implementation Plan
Telecon - Tools and Guidance Plan
4.
Statements Of Commitment
9. System Description &
13. Prepare Safety Policy/
Analysis
Objectives 17. Begin Implementation
5. Organize Team
10. Preliminary Gap
14. Calibration & Review
Analysis
Session(s)
6. Operator Profile/ CMT
Pre-brief
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SMS Implementation Guide - Appendix 1 - Level 1
Option 1 Activities:
Step 1: Initial Contact. Initial communication may come from a service provider to either their
FAA CMT (Principal Inspectors) or the FAA SMS Program Office (SMS PO). The receiving FAA
representative will complete as much of a SMS Pilot Project Inquiry Information sheet as possible and
forward this information to the SMS PO. Depending upon availability of resources, the SMS PO or
IST Lead may appoint an IST POC for the service provider (see step 5 below) at this point. It is
important for the IST POC to be appointed and involved early in the process. Coordination between
the FAA Offices will be conducted internally (see note below). A SMS Pilot Project Inquiry
Information sheet is in Attachment 1.
Note: From this point on, all communication and activity between the service provider, CMT
and the SMS PO will be coordinated and/or shared with the SMS PO Manager, Assistant
Manager, National Coordinator (703-661-0565 or 703-656-6332) and IST Lead or as directed
by SMS PO internal policy. For the purposes of this document, reference to the SMS PO will
imply conformance to the above communication/activity requirement.
Step 2: Contact CMT Management. If the CMT is not already involved, the SMS PO, SMS
IST Lead or IST POC will contact the service providers CMT Office Manager and Principal Inspectors
(PI’s). The CMT Office Manager and the PI’s will be familiarized with the SMS implementation
process and their specific roles in the process. Commitment of the CMT for time and other resources is
required prior to the service provider becoming a SMS Pilot Project participant. A sample “CMT
Contact” message is in Attachment 2.
Step 3: Initial Assessment and Coordination Telecon. The SMS PO, IST Lead or IST
POC will assess the service provider request and determine a course of action considering needs,
resources, experience level and culture between the service provider and CMT. At this stage of the
process, communication and information exchange may include telephone conversations, Polycoms,
screen sharing, email messages and attachments. No face-to-face meetings are necessary at this
juncture; however exceptions will be considered depending upon SMS PO resources available.
An initial coordination telecon between the service provider, CMT, SMS PO and IST may be
conducted to facilitate organization of activities, establish tentative schedules and answer service
provider/CMT questions. IST Lead will coordinate telecomm time and date.
NOTE: Since resources will be allocated from both the service provider and the FAA
oversight organization during the voluntary Implementation of an SMS, it is necessary that
some form of written commitment be obtained from both the service provider and the FAA
oversight organization.
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SMS Implementation Guide - Appendix 1 - Level 1
Step 5: Organize Team. The SMS Program Office or IST Lead will coordinate appointment of
an SMS IST Point-of-Contact (POC). The IST POC may be the IST Lead or another member of the
IST. The POC will act as a facilitator between the service provider and CMT, assisting them through
the SMS implementation process, as well as the point-lead, for all site visits and evaluations.
Additionally, the POC will receive assistance in the form of team members from Regional POC’s, AFS
900 Field Support Team, FAASTeam, SMS PO and/or other FAA organizations. IST POCs must be a
qualified IST member (to include SMS PO initial training) and have observed at least one complete set
of Level 1 activities, and conducted at least one set of SMS PP activities under observation of another
qualified IST POC. POCs must also be able to participate in regularly scheduled IST calibration
seminars in order to assure accuracy and currency of the service provider’s SMS implementation.
An “Information Package” on the service provider that includes any dialog or background information
the POC might need will be developed by the team. Once the IST for the service provider is formed,
the POC will coordinate the first onsite face-to-face meeting with the CMT and service provider
(Initial Workshop, Orientation Session).
After arrangements for the CMT Pre-brief have been confirmed with the Office Manager, courtesy
calls to the Principal Inspectors will be made to answer any questions they might have. If the Manager
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SMS Implementation Guide - Appendix 1 - Level 1
or Principal’s desire an agenda or subjects for discussion significantly different from the above
objectives, contact the SMS PO IST Lead for additional guidance.
The CMT Pre-brief will normally take half a day to complete. As a minimum, the Principal Inspectors
will attend the Pre-brief. Additionally, the CMT Unit Supervisors and the CMT Office Manager are
encouraged to attend. Other members of the CMT may attend as agreed upon by the IST POC and
CMT Office Manager.
All CMT questions and concerns should be addressed during the Pre-brief meeting.
Orientation: SMS Concepts. Day 2, Morning: This is the first onsite face-to-face
meeting between the service provider, CMT and IST members. The IST will present the standardized
4-hour Introduction to SMS presentation to both the service provider and CMT Management
Team/Principals. The topics within the SMS presentation should be covered in sufficient detail to
ensure a level of knowledge and standardization between the service provider and CMT needed to
support initial SMS development and evaluation activities.
Prior to the gap analyses it's beneficial to get an idea of how the service provider is structured. For
instance, the gap analyses tools have 7 operational functions listed (for air carriers, Component 1.0 b
(1) (a)) but some service providers maybe laid out in more or less divisions. This means that the
functions are grouped differently than in the gap analyses tools, but this is information that is needed
before starting the preliminary gap analysis.
Much of this information will initially be gathered during Step 6, Prepare Service provider Profile, and
from questionnaires, discussion, etc.; however all such information should then be finalized onsite
during the Orientation Session.
IST team will assist the service provider and their CMT in preparing a system description and
conducting the analysis.
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SMS Implementation Guide - Appendix 1 - Level 1
Objective: The objective of the preliminary gap analysis is to:
Familiarize service provider and CMT participants with the process of conducting a gap
analysis process.
Gain a collective awareness of the company’s configuration in terms of the allocation of
functions to organizational departments of the company. This will help to organize the
subsequent and more in-depth detailed gap analysis and planning activities.
Discuss the expectations of the SMS Framework to develop a common understanding of these
expectations in the context of the company and its operations. This may be a combined
presentation/discussion format facilitated by the IST.
Obtain an initial idea of the company’s status across its operational divisions in terms of SMS
requirements versus processes and programs already in place.
Input: The preliminary gap analysis process is confined to a high level assessment, based on the
judgment of service provider officials and discussion with the CMT and IST members to develop an
initial idea of where the service provider stands with respect to the SMS Framework expectations. It is
a high level “off the top of the head” subjective analysis; a detailed analysis will be completed later,
during Step 11, with the detailed gap analysis process.
Procedures: The preliminary gap analysis is accomplished in a group meeting environment and is
focused at the “Performance Objective” level for each Component, Element and Process contained
within the SMS Framework. The Preliminary Gap Analysis Tool is used to facilitate the analysis
process and is contained in Appendix 5 of the SMS Implementation Guide. IST team will assist the
service provider and their CMT in conducting the preliminary gap analysis.
Each SMS Component, Element and Process within the SMS Framework will be assessed for
matching service provider operational processes. These will be scored using the assessment scale
below. For those elements or processes that are deemed to have been already developed, the service
provider may provide objective evidence in terms of references to existing documentation, however, it
is not necessary to conduct a rigorous document review at this stage of the project.
The Preliminary Gap Analysis Tool may be used to summarize the results of the preliminary gap
analysis, including documentation of existing programs, but these results may also be maintained in
any manner of the service provider’s choosing.
Output: The completed Preliminary Gap Analysis Tool or other documentation should be maintained
for input into the detailed gap analysis process and as a reference for future planning and analysis.
Preliminary Gap Analysis - Assessment Scale. All elements of the preliminary gap analysis will be
given a subjective score, as defined in Figure 3, below, based on the judgment of the company’s
management. All individual questions receiving less than a score of 1 will be reviewed by the service
provider, CMT and the IST for creation of a mutually agreeable solution.
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SMS Implementation Guide - Appendix 1 - Level 1
however it does not include all SMS processes.
This objective of the SMS Framework is in place; and it
COM = Complete
does include all SMS processes.
Prior to departing from the Orientation Session, the IST will coordinate a tentative schedule for a
Calibration Session meeting. It should also be noted that additional meetings might be desirable (e.g.,
Safety Assurance Seminar) during the Level 1 process. Flexibility to respond to the needs of the CMT
and service provider should be allowed.
Input: During the detailed gap analysis, it is necessary to receive input from all organizational and
functional areas of the service provider that will be covered by the SMS in order to determine accurate
“gaps” and to facilitate a comprehensive implementation plan. It does not however, require actual
development of any of the elements during level one, beyond those listed in the SMS Framework,
Elements 1.1, 1.2 (partial), 1.3 and 4.1.1 (partial).
Procedure: The detailed gap analysis process is performed by the service provider and is
accomplished at the “Design Expectation” level for each Component, Element and Process contained
within the SMS Framework. It is a detailed analysis of each element of the SMS, as applied to each
operational process of the service provider, as compared to the expectations of the SMS Framework.
It is performed in a manner and on a schedule determined by the service provider. Involvement of
CMT members during the process is encouraged. As with the preliminary gap analysis, each SMS
Component, Element and Process within the SMS Framework will be scored using the assessment
scale below.
Documentation or “objective evidence” of processes already in place should be recorded during the
detailed gap analysis process. For those elements that are considered already developed, the service
provider should provide objective evidence in terms of references to exiting manuals or other
documentation. Objective evidence may also take the form of training material, records, interviews,
observations, correspondence (email, memo, etc.), organizational charts, meeting minutes, etc.
The Detailed Gap Analysis Tool in Appendix 6 may be used to record objective evidence; however the
company may elect their own method of recording.
SMS is currently voluntary and therefore any findings that SMS expectations are not met should not be
construed as a “deficiency.” Such findings or “gaps” discovered during the detailed gap analysis
process are used to develop a comprehensive implementation plan and represent opportunities for
future improved safety performance.
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SMS Implementation Guide - Appendix 1 - Level 1
At the conclusion of the detailed gap analysis, the results should be summarized at the
component/element/process level to facilitate more efficient implementation planning.
The detailed gap analysis should be continuously updated as the company progresses through SMS
implementation.
NOTE: The service provider may require several months to complete a thorough detailed gap
analysis. This is an extremely important activity, upon which the development and
implementation of the SMS depends. It is, therefore, more important to conduct an in depth and
comprehensive job than to meet arbitrary timelines.
Output: The results of the completed detailed gap analysis function as input to the service provider’s
implementation plan.
Detailed Gap Analysis - Assessment Scale. All questions on the Detailed Gap Analysis Tool should
receive a subjective score, as defined in Figure 4, below. All individual questions receiving less than a
score of 1 will be reviewed by the service provider, CMT and the IST for creation of a mutually
agreeable solution.
Note: IST and CMT will be available for questions and guidance while the operator is performing their
detailed gap analysis.
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SMS Implementation Guide - Appendix 1 - Level 1
Growth and Maturity: It is recommended that the detailed gap analysis be maintained, along with the
implementation plan. It should be updated on a periodic basis as a means of measuring progress as the
SMS is implemented.
Summarizing the Detailed Gap Analysis (Summary Gap Analysis): The summary gap analysis is
not a separate analysis, nor is it a required process. It is a summary of the results of the detailed gap
analysis. The results may be summarized at the performance objective level for each component,
element and process and may be used by senior management to track SMS implementation. The same
tool that was used for the preliminary gap analysis may used for the summary gap analysis.
Input: Based on the results of the detailed gap analysis, an implementation plan is prepared to describe
how the service provider plans to “fill the gaps” between their existing organization and the
objectives/expectations of the SMS Framework.
Procedures: The implementation plan need not be complex or excessively detailed but should provide
a basic roadmap to meet the overall objectives and expectations as stated in the SMS Framework to,
“…develop and implement an integrated, comprehensive SMS for [the] entire organization.”
The SMS implementation plan, which may consist of more than one document, details the actions to be
taken, by whom and in what timeframe. The implementation plan can be created in any format that is
useful to the company but should provide at least the following:
Component/element/process reference from the SMS Framework,
Brief description of the location of objective evidence indicating that the service
provider is meeting the objectives and expectations of each component, element
or process;
Brief description of the actions to be taken to resolve existing gaps and how the
actions and processes will be documented;
Responsible organization and/or individual(s), and
Expected completion date.
The implementation plan should also span the entire SMS development process through all levels of
maturity and should be updated as necessary as the project progresses. At each level, top
management's approval of the implementation plan should include allocation of necessary resources
IAW element 1.2 b (2).
Output: The completed implementation plan is the guidance for the service provider’s organization to
complete the transition to a robust SMS through Level 4.
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SMS Implementation Guide - Appendix 1 - Level 1
Forward their most current detailed gap analysis and implementation plan to their CMT and
IST at least 1 week prior to the Session;
Brief an overview of their detailed gap analysis results;
Brief gaps found and how they intend to develop processes to close the gaps;
Present objective evidence of current conformities;
Brief SMS training accomplished and future training needs;
Brief an overview of progress on their implementation plan; and
Discuss any problems and barriers to progress.
The objective is to ensure the processes are performed correctly in scope, depth & detail. These
“calibration” or “status checks” can be important parts of the process because they are an opportunity
for the IST to assist in SMS implementation course corrections, if needed, provide additional training,
if needed, and to gather data and to provide feedback to the service provider/CMT on their planning
process.
At the conclusion of the detailed gap analysis, a copy will be provided to the MITRE Corporation for
documenting purposes. Additionally, the service provider is requested to present a possible date for
exiting Level 1.
NOTE: Program reviews are “in-progress” events and the service provider may require 2 or 3
more months to finalize their gap analysis and implementation plan. Again, it should be noted that
additional meetings might be desirable (e.g., Assurance/Validation Seminar) during the Level 1
process. Flexibility during the implementation process should be allowed so the IST can respond
to the needs of the CMT and service provider.
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SMS Implementation Guide - Appendix 1 - Level 1
Step 15: Presentation of Implementation Plan.
During the final face-to-face meeting (Validation Session) between the service provider, CMT and
IST, the service provider will present a detailed overview and discussion of their SMS implementation
plan. The service provider will forward their most current detailed gap analysis and implementation
plan to their CMT and IST at least 1 week prior to the Validation Session.
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SMS Implementation Guide - Appendix 1 - Level 1
Comprehensive SMS implementation plan (Summary) for the entire organization
through SMS Implementation Level 4; and
SMS Training Plan for all employees.
At successful exit from Level 1, the IST POC will begin the SMS Participation Validation Program
(SMS Implementation Guide, Section 13) process and ensure a “Letter of Acknowledgement” is
delivered to the service provider.
Step 17: Begin Implementation. The service provider will begin implementation of Level 2
SMS Framework objectives and expectations throughout their organization.
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SMS Implementation Guide - Appendix 1 - Level 1
From Option 1,
Steps 1 thru 11
Level 3 or Above
18. Continue Implementation
4
SMS Implementation Guide - Appendix 1 - Level 1
Step 12: Gap Analysis Review.
Objective: Review and evaluate the results of the detailed gap analysis with the
focus of determining a maturity level (Level 1, 2, 3, etc.) of the organization’s
SMS.
Input: Based on the results of the detailed gap analysis, an evaluation is prepared
to determine how mature the organization’s existing SMS is in relation to the
objectives/expectations of the SMS Framework.
Procedures: The organization, CMT, and IST, meet to conduct a review of the
detailed gap analysis. The organization will:
Forward their most current detailed gap analysis to their CMT and IST at
least 2 weeks prior to the session,
Brief an overview of their detailed gap analysis results,
Where conformity exists, present objective evidence of that conformity,
Where gaps are found, if any, present a comprehensive plan on how they
intend to develop processes to resolve the gaps, and
Brief successes within the SMS training arena and future training needs.
The Gap Analysis Review may be created in any format that is useful to the
organization but should provide at least the same information that would be
contained in the Detailed Gap Analysis Tool in Appendix 6.
The Gap Analysis Review should span the entire SMS development process
through all 4 levels of SMS implementation.
Output: The completed Gap Analysis Review will be the basis for determination
of the level of implementation that the organization has achieved. It will also be
used to further develop an organization’s implementation plan leading to
complete implementation.
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SMS Implementation Guide - Appendix 1 - Level 1
Input: If gaps are discovered during the detailed gap analysis, they will be evaluated to
determine maturity level.
Procedures: At the completion of the Detailed Gap Analysis Review, the organization, CMT
and IST should mutually agree on the Level of Maturity achieved by the organization’s SMS.
Output: This “evaluation” is an important part of the process because it is an opportunity for
IST to assist in SMS implementation course corrections, if needed, provide additional training,
if needed, and to gather data and to provide feedback to the organization/CMT on their
planning process.
If no gaps exist or if all detailed gap analysis scores are at an assessment score of I
(Implemented) or above, the organization will continue to implement their SMS, as
per their plan. The CMT and IST will continue to coordinate, oversee and assist the
organization, as necessary. The IST POC will begin the SMS Participation Validation
Program (SMS Implementation Guide, Paragraph 13) process and ensure appropriate
Letter of Acknowledgement is delivered to the organization.
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SMS Implementation Guide - Appendix 1 - Level 1
4
SMS Implementation Guide - Appendix 1 - Level 1
This step involves consensus on the implementation plan between the organization, CMT and
IST. Additionally, agreement will be required that the organization has achieved all Level 1
expectations, criteria and documentation and is ready to proceed to Level 2 and/or another
level, as appropriate. The exit expectations, criteria and documentation for Level 2, 3 and 4 can
be found in the SMS Implementation Guide, Appendices 2, 3 and 4, respectively.
At completion of Level 1, the IST POC will begin the SMS Participation Validation Program
(SMS Implementation Guide, Section 13) process and insure a “Letter of Acknowledgement”
is delivered to the organization.
List of Attachments
Attachment 1 - SMS Pilot Project Inquiry Information Sheet
Attachment 2 - Sample Initial Contact Messages
Attachment 3 - Sample Initial Workshop Agenda
Attachment 4 – Example of Level 1 Exit Criteria Worksheet
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SMS Implementation Guide - Appendix 1 - Level 1
Expectations
Designator:
Address:
Notes:
4
SMS Implementation Guide - Appendix 1 - Level 1
Attachment 2
Hello, my name is, [your name], and I’m with the Federal Aviation Administration’s, Safety
Management Systems (SMS), Implementation Support Team (IST). We’re happy to know of your
interest in Safety Management Systems, and possible desire to implement SMS into your organization.
We believe that this initiative introduces the next evolutionary step in how organizations account for
safety risks in their operation.
As you might be aware, Safety Management Systems (SMS) is not an isolated company “Safety
Program,” functioning within only one department, nor a simple program that can be easily understood
and quickly instituted. In actuality, SMS involves the entire company including Top Management to
play an active roll and includes components of: Safety Policy, Safety Risk Management, Safety
Assurance, and the establishment of a Positive Safety Culture.
- Present an on-site "SMS Information and Orientation” presentation to your company. During
this time we will explain the background of the program, its functionality, the value SMS
brings to an organization, and future SMS ideology / development within the FAA.
- Provide assistance, guidance and recognition to your company as you develop and
implement a functioning SMS throughout your organization.
Depending on an organization’s size, structure, internal safety programs, values and culture, building
and maintaining an SMS may take a considerable amount of time, effort and resources. Additionally,
the SMS initiative includes the involvement of your FAA Certificate Management Team and/or
Principle Inspectors, which we help facilitate.
Your company’s request for SMS information and development is being processed and an SMS Point–
Of-Contact is being established. Once this occurs, that person will serve as your SMS liaison and will
contact you with further information and possible working relationship on this initiative.
Sincerely,
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SMS Implementation Guide - Appendix 1 - Level 1
Hello, my name is [your name]; I’m with the Federal Aviation Administration’s, Safety Management
System (SMS) Program Office, AFS 920.
One of your certificate holders, [service provider name], has shown interest in joining our SMS Pilot
Project and has requested from our office an initial evaluation of their organization’s SMS
implementation efforts. We would like to schedule an initial visit and several meetings with you, your
Principal Inspectors and [service provider name] at a time that is convenient to all involved.
If you concur, we would like to bring a SMS Implementation Support Team (IST), comprised of
[number] individuals, and spend approximately one half day briefing your CMT on SMS background,
doctrine, standards, policy, procedures and implementation tools. This would be an FAA only
meeting. The following two days would be spent briefing [service provider] and your Office
representatives much more detailed SMS orientation and conducting a SMS Preliminary Gap Analysis
of [service provider].
Our recommended Level 1 SMS Implementation Process is outlined in our SMS Implementation
Guide, Appendix 1, Pages 23 to 32. The Implementation Guide and other guidance resources may be
found at: https://avssharepoint.faa.gov/afs/900/SMS/pilot/Forms/default.aspx, under: Category: SMS
PO Document.
As you know, SMS implementation is voluntary in the United States, in difference to ICAO’s adoption
of the SMS Standard (ICAO; Annex 6 to the Convention on International Civil Aviation, and
Document 9859) and the FAA’s efforts (Order 8000.369, VS 8000.367, and AC 120-92). There is,
however, considerable interest in SMS among the U.S. aviation community. To date we have
approximately [current number] Part 121, 135 and 145 organizations enrolled in the SMS Pilot Project,
a program to assist with their SMS implementation efforts and to assist the FAA in learning best
practices.
Safety Management Systems (SMS) is not an isolated company “Safety Program,” functioning only
within one department, nor a simple program that can be easily understood and quickly instituted. In
actuality, SMS involves the entire company including top management to play an active roll in safety
management. Implementing and maintaining an SMS may take a considerable amount of time (3 to 5
years), effort and resources. Additionally, the SMS initiative includes the involvement of your FAA
Certificate Management Team and/or Principal Inspectors, which we help facilitate. However, we
believe that both your Office and the Certificate Holders organization will find that the investment in
SMS is well worth the time and effort.
If you have any questions or comments, please contact me by email or phone, either way works fine.
Sincerely,
4
SMS Implementation Guide - Appendix 1 - Level 1
Attachment 3
5
SMS Implementation Guide - Appendix 1 - Level 1
Sample Initial Workshop Agenda (Cont)
5
SMS Implementation Guide - Appendix 1 - Level 1
Attachment 4
Exit - Level 1 Criteria - Worksheet
5
SMS Implementation Guide - Appendix 1 - Level 1
Document
Output Documents
Attached?
8. Management Commitment document. Yes No
9. Safety Policy. Yes No
10. Summary of SMS Implementation Plan Yes No
10. SMS Training Plan for all employees. Yes No
IST POC:
5
SMS Implementation Guide - Appendix 2 - Level 2
Page
SMS Implementation Guide - Appendix 2 - Level 2
Appendix 2
Level 2 Expectations
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 2 - Level 2
Page
SMS Implementation Guide - Appendix 2 - Level 2
APPENDIX 2
NOTE: Some discussion and guidance from the SMS Implementation Guide is
reproduced here, so that this Appendix may be used as a stand-alone document.
Note: These known deficiencies may be based on a variety of sources including past
inspection and audit reports, accident and incident investigations and employee reports,
among others.
The Service provider will plan, organize and prepare the organization for further SMS
development. This will include complying with the following expectations in the SMS
Framework:
B. Component 2.0 Safety Risk Management (except 2.0 b (2) (a), (b) & (d),
Element 2.1 Hazard Identification and Analysis
Process 2.1.2 Identify Hazards
Element 2.2 Risk Assessment and Control
Process 2.2.1 Analyze Safety Risk
Process 2.2.2 Assess Safety Risk
Process 2.2.3 Control/Mitigate Safety Risk
Page
SMS Implementation Guide - Appendix 2 - Level 2
D. Component 4.0 Safety Promotion (except Element 4.1 Competencies and Training
and Process 4.1.1 Personnel Expectations (Competence))
Process 4.1.2 Training
Element 4.2 Communication and Awareness
Level 2 Input:
The outputs, documentation, detailed gap analysis and implementation plan from the
Level 1 exit process will provide the initial input for Level 2 development.
References:
SMS Framework, as revised,
SMS Assurance Guide, as revised, and
SMS Implementation Guide, as revised.
Page
SMS Implementation Guide - Appendix 2 - Level 2
At this step, the service provider develops and implements basic safety risk management
and safety assurance processes. Information acquisition, processing, and analysis
functions are implemented and a tracking system for risk control and corrective actions is
developed. This allows the service provider to systematically address known problems
and react to newly identified problems as they occur and to develop appropriate remedial
action.
At the end of Level 2, most of the essential safety management structure and basic
identification, analysis and assessment functions of an SMS will be in place, however
because the forward looking systems and task analyses have not yet been conducted, the
system is still functioning at a reactive level. For this reason, this level is termed
“reactive.” While this is not the final objective of an SMS, it is an important step in the
evolution of safety management capabilities.
Level 2 Procedures:
Level 2 Output:
Completion Criteria: The documentation and performance desired for level 2 exit status
assessment are listed below:
1. Processes and procedures documented for operating the SMS to the level of
reactive analysis, assessment and mitigating actions;
4. Conducted SMS training for the staff directly involved in the SMS process to at
least the level necessary for the SMS reactive processes;
5. Apply Safety Risk Management (SRM) processes and procedures to at least one
known (existing) hazard and initiate the mitigation process to control / mitigate the
risk associated with the hazard.;
Page
SMS Implementation Guide - Appendix 2 - Level 2
6. Update the detailed gap analysis on the entire organization for all elements of the
SMS Framework; and
7. Update the comprehensive SMS implementation plan for all elements to take the
service provider through Level 4.
Documents: Documentation or objective evidence for the following (The elements and
processes implemented during level 1 have already been documented and need not be
repeated for Level 2):
8. Objective evidence that SRM processes and procedures have been applied to at
least one existing hazard and that the mitigation process has been initiated.
9. Updated comprehensive SMS implementation plan for all elements to take the
service provider through Level 4.
Once the process and procedural items listed above have been completed, there will a
joint assessment of the status of the service provider’s SMS development. The service
provider will present their progress (to include updated and current detailed gap analysis
and implementation plan) to their oversight organization and the IST prior to proceeding
to Level 3.
In conducting the document review and assessment, it should be noted that the objective
is to develop and implement the specific processes and procedures necessary for applying
SMS reactively for the systems listed in the SMS Framework, Component 1.0 b (1) (a)
or (b), as appropriate.
At completion of Level 2, the IST POC will begin the SMS Participation Validation
Program (SMS Implementation Guide, Section 13) process and ensure a “Letter of
Acknowledgement” is delivered to the Service provider.
List of Attachments
Page
SMS Implementation Guide - Appendix 2 - Level 2
Attachment 1
Exit - Level 2 Criteria – Worksheet
Page
SMS Implementation Guide - Appendix 2 - Level 2
Page
SMS Implementation Guide - Appendix 3 – Level 3
Page
SMS Implementation Guide - Appendix 3 – Level 3
Appendix 3
Level 3 Expectations
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 3 – Level 3
Page
SMS Implementation Guide - Appendix 3 – Level 3
APPENDIX 3
NOTE: Some discussion and guidance from the SMS Implementation Guide is
reproduced here, so that this Appendix maybe used as a stand-alone document.
The service provider will develop processes to understand the critical characteristics of its
systems and operational environment and apply this knowledge to the identification of
hazards, risk decision-making, and the design of risk controls.
Level 3 Objective:
The first overall objective of SMS development is captured in the first objective of the
policy component of the SMS Framework:
Page
SMS Implementation Guide - Appendix 3 – Level 3
Level 3 Input:
The outputs, documentation and Implementation Plan from the Level 2 Exit process will
provide the initial input for Level 2 development. Additional input includes results from
Internal Evaluation Program, ASAP, CAS, FOQA, previous internal and external audit
reports, accident and incident investigations and employee reports.
References:
SMS Framework, as revised,
SMS Assurance Guide, as revised, and
SMS Implementation Guide, as revised.
Level 3 Procedure:
2. System and task descriptions will be developed to the level of detail necessary
to:
Identify hazards;
Develop operational procedures; and
Develop and implement risk controls.
5. Incorporate identified hazards from System and Task Analyses into SRM
process.
Page
SMS Implementation Guide - Appendix 3 – Level 3
Level 3 Output:
Completion Criteria: Once the objectives and procedures outlined above have been
completed, there will be a joint assessment of the status of SMS development by the
service provider, the oversight organization and the IST prior to proceeding to Level 4.
The documentation and Gap Analysis Tools used for Level 3 status assessment are listed
below. In conducting the document review and assessment, it should be noted that the
objective is to develop and implement the full capabilities necessary for applying SMS.
Assessment Criteria: The service provider must have accomplished at least the
following:
Page
SMS Implementation Guide - Appendix 3 – Level 3
Documents: All processes and procedures for operating the SMS should be documented.
This document, or documents, should cover all processes and procedures necessary from
information gathering through SRM and mitigation. As the Safety Assurance processes
are not mature enough, at this point, to be verifiable, as a minimum the policy and
procedures will be documented. The service provider must provide documentation or
objective evidence for the following:
Objective evidence that SRM processes and procedures have been applied to all
Component 2.0 b (2), (a), (b) & (d), operating processes;
Objective evidence that SRM processes and procedures have been applied to at
least one existing hazard and that the mitigation process has been initiated;
When conducting the document review and assessment, the objective is to develop and
implement the specific processes and procedures necessary for applying SMS proactively
for the systems listed in the SMS Framework, Component 1.0 b (1), (a) or (b), as
appropriate.
At completion of Level 3, the IST POC will begin the SMS Pilot Project and Voluntary
Program Validation (SMS Implementation Guide, Paragraph 11) process and insure a
Letter of Participation is delivered to the Service Provider.
List of Attachments
Attachment 1
Exit - Level 3 Criteria - Worksheet
Page
SMS Implementation Guide - Appendix 3 – Level 3
8. All applicable SMS processes and procedures must have been applied to at
least one existing hazard and the mitigation process must have been initiated.
9. Complete SMS training for the staff directly involved in the SMS process to
the level of accomplishing all SMS processes;
10. Complete employee training commensurate with this level of
implementation phase maturity;
IST POC:
Page
SMS Implementation Guide - Appendix 4 – Level 4
Page
SMS Implementation Guide - Appendix 4 – Level 4
Appendix 4
Level 4 Expectations
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 4 – Level 4
APPENDIX 4
NOTE: Some discussion and guidance from the SMS Implementation Guide is
reproduced here, so that this Appendix maybe used as a stand-alone document.
Level 4 Objective
The overall objective of SMS development is captured in the first objective of the policy
component of the SMS Framework:
The specific objective of Level 4 is for the service provider to verify the performance and
effectiveness of their SMS management practices and operational processes.
Level 4 Input:
To be developed
References:
SMS Framework, as revised,
SMS Assurance Guide, as revised, and
SMS Implementation Guide, as revised.
Level 4 Procedure:
To be developed
Level 4 Output:
To be developed
Page
SMS Implementation Guide - Appendix 5 – Preliminary
Gap Analysis Tool
Appendix 5
Preliminary Gap Analysis
Tool
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 5 – Preliminary
Gap Analysis Tool
APPENDIX 5
The following extract of the Preliminary Gap Analysis Tool is designed for Air Carrier
(AC) operators.
The Preliminary Gap Analysis Tool for Maintenance Repair Organizations (MRO) is
identical, except for the column headings.
The full complete electronic copies of both Air Carrier and Maintenance Repair
Organizations Preliminary Gap Analysis Tools are available for download at:
For questions, please contact your oversight organization or the SMS Program Office at:
The electronic copies of the Preliminary Gap Analysis Tool are not password protected
and may be edited to reflect the organizational structure unique to specific organizations.
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
The organization will appoint a management representative to manage, monitor and
coordinate the SMS processes throughout its organization.
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
The organization will describe and analyze its systems, operations, and operational
environment to gain an understanding of critical design and performance factors, processes,
and activities to identify hazards.
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
Performance Objective
The organization will monitor, measure, and evaluate the performance of their systems to
identify new hazards, measure the effectiveness of risk controls, (to include preventative and
corrective actions) and ensure compliance with regulatory requirements.
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
The organization will establish procedures to collect data and investigate incidents,
accidents, and instances of potential regulatory non-compliance to identify potential new
hazards or risk control failures.
The organization’s management will identify and determine acceptable safety risk for
changes within the organization that may affect established processes and services by new
system design, changes to existing system designs, new operations/procedures, or modified
operations/procedures.
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
The organization will promote continuous improvement of its SMS through recurring
application of Safety Risk Management (Component 2.0), Safety Assurance (Component
3.0), and by using safety lessons learned and communicating them to all personnel.
Page
SMS Implementation Guide - Appendix 5 – Preliminary Gap Analysis
The organization will develop, document, deliver and regularly evaluate training
necessary to meet competency requirements of Process 4.1.1 b, (1).
Page
SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Appendix 6
Detailed Gap Analysis
Tool
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
APPENDIX 6
The following extract of the Detailed Gap Analysis Tool is designed for Air Carrier (AC) operators.
The Detailed Gap Analysis Tool for Maintenance Repair Organizations (MRO) is identical, except for lines 13
thru 30 and the column headings.
The full complete electronic copies of both Air Carrier and Maintenance Repair Organizations Detailed Gap
Analysis Tools are available for download at:
For questions, please contact your oversight organization or the SMS Program Office at:
The electronic copies of the Detailed Gap Analysis Tool are not password protected and may be edited to reflect
the organizational structure unique to specific organizations.
Page
SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Flight Operations?
Reference: SMS Framework: 1.0 b, (1) (a) (1) (P)
Operational Control (Dispatch/Flight
Following)?
Reference: SMS Framework: 1.0 b, (1) (a) (2) (P)
Cabin safety?
Reference: SMS Framework: 1.0 b, (1) (a) (4) (P)
Cargo handling?
Reference: SMS Framework: 1.0 b, (1) (a) (6) (P)
Training?
Reference: SMS Framework: 1.0 b, (1) (a) (7) (P)
Procedure: Management
Does the organization require the SMS
processes to be -
Documented?
Reference: SMS Framework: 1.0 b, (2)(a) (P)
Monitored?
Reference: SMS Framework: 1.0 b, (2) (b) (P)
Measured?
Reference: SMS Framework: 1.0 b, (2) (c) (P)
Analyzed?
Reference: SMS Framework: 1.0 b, (2) (d) (P)
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Does the organization promote a positive
safety culture as in Component 4.0 B?
Reference: SMS Framework 1.0 b, (4)(a) (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Reference: SMS Framework 1.0 b, (3)(a) (I/P)
Monitored?
Reference: SMS Framework 1.0 b, (3) (b) (I/P)
Measured?
Reference: SMS Framework 1.0 b, (3) (c) (I/P)
Analyzed?
Reference: SMS Framework 1.0 b, (3) (d) (I/P)
Controls
Does the organization establish and maintain
supervisory and operational controls to ensure
procedures are followed for safety- related
operations and activities?
Reference: SMS Framework 1.0 b, (4) (f) (C)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Design Expectations
Management Accountability
Does top management define the
organization’s Safety Policy?
Reference: SMS Framework 1.1 b, (1) (P/R/A)
Procedure
Does the organization’s safety policy include the
following -
A commitment to implement and maintain the
SMS?
Reference: SMS Framework 1.1 b, (2)(a) (P)
A commitment to continuously improve the
level of safety?
Reference: SMS Framework 1.1 b, (2) (b) (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Reference: SMS Framework 1.1 b, (2) (g) (I)
Does the Safety Policy provide guidance to
management on reviewing safety objectives?
Reference: SMS Framework 1.1 b, (2) (h) (I)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Performance Objective
The organization will define, document, and
communicate the safety roles, responsibilities,
and authorities throughout its
organization.
Design Expectations
Management Accountability
Does the organization ensure top management
has the ultimate responsibility for the SMS?
Reference: SMS Framework 1.2 b, (1) (R/A)
Documented?
Reference: SMS Framework 1.2 b, (3) (b) (P)
Communicated throughout the
organization?
Reference: SMS Framework 1.2 b, (3) (c) (P)
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The organization will periodically measure
performance objectives and design
expectations of the Management Commitment
and Safety Accountability Element?
Design Expectations
Management Responsibility/Procedure
Did top management appoint a member of
management who, irrespective of other
responsibilities, will be responsible for and
authorized to -
Ensure that SMS processes are established,
implemented, and maintained?
Reference: SMS Framework 1.3 b, (1)(a) (R/A/P)
Report to top management on the
performance of the SMS and what needs to be
improved?
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Ensure the organization communicates its
safety requirements throughout the
organization?
Design Expectations
Management Responsibility
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
The organization will clearly identify who is
responsible for the quality of the Emergency
Preparedness and Response Process and
associated documentation. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization establish procedures
across all operational departments as expected
in Safety Policy and Objectives Component 1.0
b, (1)(a) or (b), to -
Identify hazards which have potential for
accidents, incidents or operational
emergencies?
Reference: SMS Framework 1.4 b, (1) (P)
Coordinate and plan the organization’s
response to accidents, incidents or
operational emergencies?
Reference: SMS Framework 1.4 b, (2) (P)
Execute periodic exercises of the
organization’s emergency response
procedures?
Reference: SMS Framework 1.4 b, (3) (P)
Outputs and Measures
The organization will:(1) identify interfaces
between the emergency response functions of
different operational elements of the organization,
and (2) periodically measure performance
objectives and design expectations of the
Emergency Preparedness and Response Element.
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Has the organization developed and implemented
procedures that it will follow in the event of an
accident, incident or operational emergency to
mitigate the effects of these events?
Performance Objective
The organization will have documented safety
policies, objectives, procedures, a
document/record management process, and a
management plan that meet organizational safety
expectations and objectives.
Design Expectations
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the
Documentation and Records Process.
Procedures will also define who is responsible
for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure: Document Contents
Does the organization establish and maintain, in
paper or electronic format, information to describe
the following -
Safety policies?
Reference: SMS Framework 1.5 b, (1)(a) (P)
Safety objectives?
Reference: SMS Framework 1.5 b, (1) (b) (P)
SMS expectations?
Reference: SMS Framework 1.5 b, (1) (c) (P)
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Safety-related procedures and processes?
Reference: SMS Framework 1.5 b, (1) (d) (P)
SMS outputs?
Reference: SMS Framework 1.5 b, (1) (g) (P)
Procedure: Document Quality
Does the organization require all
documentation be -
Legible?
Reference: SMS Framework 1.5 b, (3)(a) (1) (P)
Readily identifiable?
Reference: SMS Framework 1.5 b, (3)(a) 3 (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
They are easily located?
Reference: SMS Framework 1.5 b, (3) (b) 1 (P)
Identified?
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Maintained?
Reference: SMS Framework 1.5 b, (4)(a) (2) (P)
Disposed of?
Reference: SMS Framework 1.5 b, (4)(a) (3) (P)
Legible?
Reference: SMS Framework 1.5 b, (4) (b) (1) (P)
Easy to identify?
Reference: SMS Framework 1.5 b, (4) (b) (2) (P)
Easy to find?
Reference: SMS Framework 1.5 b, (4) (c) (1) (P)
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Has the organization clearly defined and
documented (in paper or electronic format) safety
policies, objectives, procedures, and
document/record maintenance processes and
established, implemented, and maintained a safety
management plan that meets the safety
expectations and objectives?
Design Expectations
Input
The organization will identify inputs (interfaces)
for this Component obtained from the critical
expectations of its systems and operational
environment?
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Safety Risk
Management Process. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Procedure
Does the organization’s SMS, at a minimum,
include the following processes -
System description and task analysis?
Reference: SMS Framework 2.0 b, (1) (a) (P)
Hazard Identification?
Reference: SMS Framework 2.0 b, (1) (b) (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Does the organization establish feedback loops
between assurance functions described in the
Comtinuous Monitoring Process 3.1.1, b, to
evaluate the effectiveness of safety risk controls?
Likelihood levels?
Reference: SMS Framework 2.0 b, (4) (b)(2) (P)
Level of management that can make safety risk
acceptance decisions in accordance with Element
1.2 b (3)?
Reference: SMS Framework 2.0 b, (4) c)(P/R/A)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
The organization will: (1) identify interfaces
between the Safety Risk Management
Component (this Component) and the Safety
Assurance Component (3.0), and (2) periodically
measure performance objectives and design
expectations of the safety risk management
component.
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Performance Objectives
The organization will describe and analyze its
systems, operations, and operational environment
to gain an understanding of critical design and
performance factors, processes, and activities to
identify hazards.
Design Expectations
Input
Inputs (interfaces) for the System Description and
Task Analysis process will be obtained from the
Safety Risk Management Component 2.0 b, (2).
Reference: SMS Framework 2.0 b, (2) (I).
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the System
Description and Task Analysis Process.
Procedures will also define who is responsible
for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization develop system
descriptions and task analysis to the level of
detail necessary to -
Identify hazards?
Reference: SMS Framework 2.1.1 b, (1)(a) (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
The organization will: (1) identify interfaces
between the system description and task
analysis function (this process) and the Hazard
Identification Process 2.1.2 below, and
(2) periodically measure performance
objectives and design expectations of the
System Description and Task Analysis
Process (2.1.1).
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and operational
controls to ensure the effectiveness of the
System Description and Task Analysis Process
(2.1.1).
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b (1) & (2)
(C)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Design Expectations
Input
Inputs (interfaces) for the Hazard Identification
Process will be obtained from the System
Description and Task Analysis Process 2.1.1, to
include a new hazard identified from the Safety
Assurance Component 3.0, failures of risk
controls due to design deficiencies found in the
System Assessment Process 3.1.8 (b)(3), and/or
from any other source.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Hazard
Identification Process. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Does the organization manage hazard information
through the entire Safety Rsk Management
Process?
Reference: SMS Framework 2.1.2 b, (2) (b) (P)
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the Hazard Identification
Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Process 2.2.1 Analyze Safety
Risk
Performance Objective
The organization will determine and analyze the
severity and likelihood of potential events
associated with identified hazards and will
identify risk factors associated with unacceptable
levels of severity or likelihood.
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Hazard Identification
Process (2.1.2).
Reference: SMS Framework 1.5 b, (1) (f) (I).
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Safety Risk
Analysis Process. Procedures will also define who
is responsible for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization’s safety risk analysis
functions include -
Analysis of existing safety risk controls?
Reference: SMS Framework 2.2.1 b, (1)(a) (P)
Triggering mechanisms?
Reference: SMS Framework 2.2.1 b, (1) (b) (P)
Safety risk of a reasonably likely outcome
from the existence of a hazard?
Reference: SMS Framework 2.2.1 b, (1) (c) (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Does the organization’s reasonably likely
outcomes from the existence of a hazard,
include estimations of the following -
Likelihood?
Reference: SMS Framework 2.2.1 b, (1) (c) 1 (P)
Severity?
Reference: SMS Framework 2.2.1 b, (1) (c) 2 (P)
Outputs and Measures
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Has the organization determined and analyzed
the factors related to the severity and likelihood
of potential events associated with identified
hazards and identified factors associated with
unacceptable levels of severity or likelihood?
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Safety Risk Analysis Process
2.2.1 in terms of estimated severity and
likelihood.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Safety Risk
Assessment Process. Procedures will also define
who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization analyze each hazard for its
safety risk acceptability using their safety risk
acceptance process as described in the SMS
Framework Component 2.0, b (4)?
Reference: SMS Framework 2.2.2 b, (P)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Outputs and Measures
The organization will: (1) identify interfaces
between the risk assessment functions (this
process) and the Control/Mitigate Safety Risk
Process 2.2.3. below, and (2) periodically
measure performance objectives and design
expectations of the Safety Risk Assessment
Process.
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
Controls
The organization will ensure that: (1) procedures
are followed for safety-related operations and
activities, and (2) they periodically review
supervisory and operational controls to ensure
the effectiveness of the Safety Risk Assessment
Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
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The organization will design and implement a risk
control for each identified hazard for which there
is an unacceptable risk, to reduce risk to
acceptable levels. The potential for residual risk
and substitute risk will be analyzed before
implementing risk controls.
NOTE: Although Process 2.2.3 is very similar to
the Preventive/Corrective Action Process 3.3.1,
the primary differences are:
Process 2.2.3 is used during the design of a
system (often looking to the future) or in the
redesign of a non-performing system where
system requirements are being met, however the
system is not producing the desired results.
Design Expectations
Input
Inputs (interfaces) for the Control/Mitigation
Safety Risk process will be obtained from the
Safety Risk Assessment Process 2.2.2.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the
Control/Mitigate Safety Risk Process.
Procedures will also define who is responsible
for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
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Procedure
Does the organization have a safety risk
control/mitigation plan for each hazard with
unacceptable risk?
Reference: SMS Framework 2.2.3 b, (1) (P/C)
Documented?
Reference: SMS Framework 2.2.3 b, (2) (c) (P)
Does the organization ensure that substitute risk
will be evaluated when creating safety risk
controls and mitigations?
Reference: SMS Framework 2.2.3 b, (3) (P/C)
Outputs and Measures
The organization will: (1) identify interfaces
between the risk control/mitigation functions (this
process) and the Safety Assurance Component
3.0, specifically 3.1.1 thru 3.1.6, below, and (2)
periodically measure performance objectives and
design expectations of the risk Control/Mitigate
Safety Risk Process.
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
Controls
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The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the safety risk control
process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
Design Expectations
Input
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Inputs (interfaces) for this component will be
obtained from the Safety Risk Management
Component 2.0.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Safety
Assurance Component. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization monitor their systems and
operations to -
Operational processes?
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Reference: SMS Framework 3.0 b, (2)(a) (P)
The SMS?
Reference: SMS Framework 3.0 b, (2) (b) (P)
Outputs and Measures
The organization will identify interfaces
between the data acquisition processes
(3.1.1 to 3.1.6) and -
The system assessment process (2.2.2)
Reference: SMS Framework 1.5 b, (1) (f) (I)
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Has the organization monitored, measured, and
evaluated the performance of their systems to
identify new hazards, measure the effectiveness of
risk controls, (to include preventative and
corrective actions) and
ensured compliance with regulatory
requirements?
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Risk Assessment Process
2.2.2, Risk Control/Mitigation Process 2.2.3,
System Assessment Process 3.1.8 or
Preventive/Corrective Action Process 3.3.1.
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Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization monitor operational data
(e.g., duty logs, crew reports, work cards,
process sheets, and reports from the employee
safety feedback system specified in Process
3.1.6) to -
Determine whether it conforms to safety
risk controls (described in Process 2.2.3)?
Reference: SMS Framework 3.1.1 b, (1)(a) (P)
Identify hazards?
Reference: SMS Framework 3.1.1 b, (1) (d) (P)
Does the organization monitor products and
services from contractors?
Reference: SMS Framework 3.1.1 b, (2) (P)
Outputs and Measures
The organization will: (1) identify interfaces
between these continuous monitoring functions
and the Analysis of Data Process
3.1.7 below, and (2) periodically measure
performance objectives and design
expectations of the Continuous Monitoring
Process.
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
Controls
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The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the effectiveness
of the Continuous Monitoring Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Control/Mitigate Safety
Process 2.2.3.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
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The organization will clearly identify who is
responsible for the quality of the Internal
Auditing Process. Procedures will also define
who is responsible for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure:
Does the organization’s line management
ensure regular internal audits of safety- related
functions of the organization’s operational
processes (production system) are conducted?
Reference: SMS Framework 3.1.2 b, (1) (P)
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Results of previous audits?
Reference: SMS Framework 3.1.2 b, (3) (b) (P)
Scope?
Frequency?
Methods?
Expectations for -
Planning audits?
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Conducting audits?
Reporting results?
Maintaining records?
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Has the organization performed regularly
scheduled internal audits of its operational
processes, including those performed by
contractors, to determine the performance and
effectiveness of risk controls?
Design Expectations
Input
Inputs (interfaces) for this process will be obtained
from the Risk Assessment Process
2.2.2 or Control/Mitigate Safety Risk Process
2.2.3.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Internal
Evaluation Process. Procedures will also define
who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
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Does the organization ensure internal evaluations
of operational processes and the SMS are
conducted at planned intervals, to determine that
the SMS conforms to objectives and
expectations? Note: Sampling of SMS output
measurement is a primary control under
Component 1.0, b, (3) (c) and (4) (e).
Reference: SMS Framework 3.1.3 b, (1) (P)
Scope?
Frequency?
Methods?
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Reference: SMS Framework 3.1.3 b, (3) (b) (P)
Procedure: Documentation
Does the organization’s document
procedures include -
Evaluation responsibilities?
Reference: SMS Framework 3.1.3 b, (3) (c)(1) (P)
Requirements for -
Planning evaluations?
Reference: SMS Framework 3.1.3 b, (3) (c) 2 (a)
(P)
Conducting evaluations?
Reference: SMS Framework 3.1.3 b, (3) (c) 2 (b)
(P)
Reporting results?
Reference: SMS Framework 3.1.3 b, (3) (c) 2 (c)
(P)
Maintaining records?
Reference: SMS Framework 3.1.3 b, (3) (c) 2 (d)
(P)
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Does the organization ensure the person or
organization performing evaluations of
operational processes are independent of the
process being evaluated?
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the Internal Evaluation
Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
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The organization will include the results of
assessments performed by oversight
organizations, and other external audit results,
in its data analysis.
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Control/Mitigate Safety Risk
Process 2.2.3 and from the FAA and/or other
external agencies.
Procedure
Does the organization ensure it includes the
results of oversight organization audits, and other
external audit results, in the analyses conducted
under SMS Framework Analysis of Data Process
3.1.7?
Reference: SMS Framework 3.1.4 b, (P/I)
Outputs and Measures
The organization will: (1) identify interfaces
between this process and the Analysis of Data
Process 3.1.7 below, and (2) periodically
measure performance objectives and design
expectations of the External Auditing Process.
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
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Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the External Auditing
Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Control/Mitigate Safety
Risk Process 2.2.3 and as needed upon
occurrence of events.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
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The organization will clearly identify who is
responsible for the quality of the Investigation
Process. Procedures will also define who is
responsible for accomplishing the process.
Procedure
Does the organization ensure it collects data on-
Incidents?
Reference: SMS Framework 3.1.5 b, (1)(a) (P)
Accidents?
Reference: SMS Framework 3.1.5 b, (1) (b) (P)
Incidents?
Reference: SMS Framework 3.1.5 b, (2) (b) (P)
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Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and operational
controls to ensure the effectiveness of the
Investigation Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
Design Expectations
Input
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Inputs (interfaces) for the Employee
Reporting and Feedback System will be
obtained from employees.
Management Responsibility
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Reference: SMS Framework 3.1.6 b, (4) (P)
Controls
The organization will ensure that: (1) procedures
are followed for safety-related operations and
activities, and (2) they periodically review
supervisory and operational controls to ensure the
effectiveness of the Employee Reporting and
Feedback Process.
Performance Objective
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The organization will analyze the data
described in SMS Framework Processes
3.1.1 thru 3.1.6, to assess the risk controls’
performance and effectiveness in the
organization’s operational processes and the
SMS, and to identify root causes of deficiencies
and potential new hazards.
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the data acquisition processes
3.1.1 thru 3.1.6.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Analysis of
Data Process. Procedures will also define who
is responsible for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization analyze the data that it
collects to demonstrate the effectiveness of -
Risk controls in the organization’s
operational processes (SMS Framework
Safety Policy Component 1.0 b, (1) (a) &
(b))?
Reference: SMS Framework 3.1.7 b, (1) (a) (P)
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Does the organization ensure it analyzes the data
it collects to identify root causes of deficiencies
and potential new hazards and evaluate where
improvements can be made in the organization’s
-
Operational processes (SMS Framework
Safety Policy Component 1.0 b, (1) (a) & (b))?
Reference: SMS Framework 3.1.7 b, (2) (a) (P)
The SMS?
Reference: SMS Framework 3.1.7 b, (2) (b) (P)
Outputs and Measures
The organization will: (1) identify interfaces
between this process and the System Assessment
Process 3.1.8 below, and (2) periodically
measure performance objectives and design
expectations of the Analysis of Data Process.
Controls
The organization will ensure that: (1) procedures
are followed for safety-related operations and
activities, and (2) they periodically review
supervisory and operational controls to ensure the
effectiveness of the Analysis of Data Process.
Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
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Has the organization analyzed the data
described in SMS Framework processes
3.1.1 thru 3.1.6 to assess the risk controls’
performance and effectiveness in the
organization’s operational processes and the
SMS and to identify root causes of deficiencies
and potential new hazards?
Process 3.1.8 System
Assessment
Performance Objective
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the Analysis of Data Process
3.1.7.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the System
Assessment Process. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
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Safety-related functions of operational processes
(Safety Policy Component 1.0 b
(1) (a)) against their requirements?
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Reference: SMS Framework 3.1.8 b, (4) (P/I)
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the System Assessment
Process.
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Has the organization assessed risk controls’
performance and effectiveness, conformance with
SMS requirements, and the objectives of the
safety policy?
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from proposed changes to systems,
processes, procedures, or organizational
structures.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Management of
Change Process. Procedures will also define who
is responsible for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
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Does the organization ensure it does not
implement any of the following until the level of
safety risk of each identified hazard is determined
to be acceptable for -
Controls
The organization will ensure that: (1) procedures
are followed for safety-related operations and
activities, and (2) they periodically review
supervisory and operational controls to ensure
the effectiveness of the Management of Change
Process.
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Reference: (1) SMS Framework: 1.0 b, (4) (f): (2) SMS
Framework 1.1 b, (2) k); 3.1.3 b, (1); 3.3.2, b, (1) & (2)
(C)
Performance Objective
The organization will promote continuous
improvement of its SMS through recurring
application of SRM (Component 2.0), SA
(Component 3.0), and by using safety lessons
learned and communicating them to all
personnel.
Design Expectations
Input
Inputs (interfaces) for this process will be
obtained through continuous application of
Safety Risk Management (Component 2.0),
Safety Assurance (Component 3.0) and the
outputs of the SMS, including safety lessons
learned.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
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The organization will clearly identify who is
responsible for the quality of the Continual
Improvement Process. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization continuously improve the
effectiveness of the SMS and of safety risk
controls through the use of the safety and quality
policies, objectives, audit and evaluation results,
analysis of data, corrective and preventive actions,
and management reviews?
Reference: SMS Framework 3.3 b, (1) (P)
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The organization will: (1) ensure that trend
analysis of safety and quality policies,
objectives, audit and evaluation results, analysis
of data, and corrective and preventive actions are
interfaced with Management Review Process
3.3.2, below), and (2) periodically measure
performance objectives and design expectations
of the Continual Improvement Process.
Controls
The organization will ensure that: (1) procedures
are followed for safety-related operations and
activities, and (2) they periodically review
supervisory and operational controls to ensure the
effectiveness of the Continuous Improvement
Process.
Process 3.3.1
Preventive/Corrective Action
Performance Objective
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The organization will take preventive and
corrective action to eliminate the causes or
potential causes of nonconformance
identified during analysis, to prevent
recurrence.
NOTE: Although Process 2.2.3 (Control/Mitigate
Safety Risk) is very similar to Process 3.3.1, the
primary differences are:
Process 2.2.3 is used during the design of a
system (often looking to the future) or in the
redesign of a non-performing system where
system requirements are being met, but the
system is not producing the desired results.
Process 2.2.3 is also used where new
hazards are discovered during Safety
Assurance that were not taken into account
during initial design.
Process 3.3.1 is used to develop actions to
bring a non-performing system back into
conformance to its design requirements.
Design Expectations
Inputs
Inputs (interfaces) for this process will be
obtained from System Assessments (Process
3.1.8) with findings of non-performing risk
controls.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
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Procedure
Does the organization develop the following -
Preventive actions for identified potential
nonconformities with risk controls?
Reference: SMS Framework 3.3.1 b, (1) (a) (P)
Preventive actions?
Reference: SMS Framework 3.3.1 b, (2) (a) (P)
Corrective actions?
Reference: SMS Framework 3.3.1 b, (2)(b) (P)
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The organization will: (1) identify interfaces
between this process and the Continuous
Monitoring Process 3.1.1 above, and (2)
periodically measure performance objectives and
design expectations of the Preventive and
Corrective Action Process.
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the Preventive and Corrective
Action Process.
Performance Objective
Top management will conduct regular reviews of
the SMS to assess the performance and
effectiveness of an organization’s operational
processes and the need improvements.
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Design Expectations
Input
Inputs (interfaces) for this process will be
obtained from the outputs of Safety Risk
Management (Component 2.0) and Safety
Assurance (Component 3.0) activities including
-
Hazard identification (Process 2.1.2)
Risk analysis (severity and likelihood) (Process
2.2.1)
Risk assessments (Process 2.2.2)
Risk control/mitigation plans (Process
2.2.3)
Results of analysis of data (Process 3.1.7)
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Management
Review Process. Procedures will also define who
is responsible for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does top management conduct regular reviews of
the SMS, including the outputs of the Safety Risk
Management Process, the outputs of the Safety
Assurance Process, and safety lessons learned?
Reference: SMS Framework 3.3.2 b, (1)(a), (b) & (c)
(P)
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Does top management include in its reviews of
the SMS, an assessment of the need for
improvements to the organization’s operational
processes and SMS?
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the Management Review
Process.
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Bottom Line Assessment
Design Expectations
Input
Inputs (interfaces) will be identified between top
management and organizational personnel.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Safety Promotion
Component (4.0). Procedures will also define who
is responsible for accomplishing the process.
Reference: SMS Framework 1.2 b, (3) (R/A)
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Procedure/Output/Measure
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The organization will periodically measure
performance objectives and design
expectations of the Safety Promotion
Component.
Reference: (1) SMS Framework 1.5 b, (1) (f): (2) SMS
Framework note at 3.1.3 & 1.0 b, (2) (c) and (3) (c);
3.1.3 b, (1) (PM/I)
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the Safety Promotion
Component.
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Design Expectations
Input
Inputs (interfaces) for this process will be
identified between top management and the key
safety personnel referenced in Management
Commitment and Safety Accountabilities
Element 1.2 b, (3) & Key Safety Personnel
Element 1.3.
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the Personnel
Expectations Process. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
Does the organization identify the competency
requirements for safety-related positions
identified in Management Commitment and
Safety Accountabilities Element 1.2 b, (3) &
Key Safety Personnel Element 1.3?
Reference: SMS Framework 4.1.1 b, (1) (P)
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The organization will periodically measure
performance objectives and design expectations
of the Personnel Expectations Process.
Reference: SMS Framework note at 3.1.3 & 1.0 b, (2)
(c) and (3) (c); 3.1.3 b, (1) (PM/I)
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the effectiveness
of the personnel qualification and training
process.
Performance Objective
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Design Expectations
Input
Inputs (interfaces) for the Training Process will
be obtained through the outputs of the SMS
and the documented competency expectations
of Personnel Expectations Process 4.1.1 b, (1)
Reference: SMS Framework 1.5 b, (1) (f) (I)
Management Responsibility
The organization will clearly identify who is
responsible for the quality of the
SMS Training Process. Procedures will also
define who is responsible for accomplishing the
process.
Reference: SMS Framework 1.2 b, (3) (R/A)
Procedure
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Does the organization’s employees receive
training commensurate with their -
Controls
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Does the organization ensure that safety- related
training media is periodically reviewed and
updated for target populations?
Design Expectations
Input
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Inputs (interfaces) for this process will be
obtained from the outputs of Safety Risk
Management (2.0) and Safety Assurance
(3.0) including -
Hazard identification (2.1.2)
Risk severity and likelihood (2.2.1)
Risk assessments (2.2.2)
Risk control/mitigation plans (2.2.3)
Safety lessons learned
Results of analysis of data (3.1.7)
Reference: SMS Framework 1.5 b, (1) (f) & 3.3 b, (2)
(I)
Management Responsibility
Procedure/Output/Measure
Does the organization ensure it communicates
outputs of the SMS, rationale behind controls,
preventive and corrective actions and ensure
awareness of SMS objectives to its employees?
Reference: SMS Framework 4.2 b, (1) (P/PM/I)
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SMS Implementation Guide - Appendix 6 – Detailed Gap Analysis
Does the organization interface with other
organization’s SMSs to cooperatively manage
issues of mutual concern?
Controls
The organization will ensure that: (1)
procedures are followed for safety-related
operations and activities, and (2) they
periodically review supervisory and
operational controls to ensure the
effectiveness of the Communication and
Awareness Process.
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SMS Implementation Guide - Appendix 7 – SMS Assessment Protocol
for Manager/Supervisor
Appendix 7
SMS Assessment Protocol for
Manager/Supervisor
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 7 – SMS Assessment Protocol
for Manager/Supervisor
To be developed
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SMS Implementation Guide - Appendix 8 – Cross reference between AC 120-
92 and the SMS Framework
Appendix 8
Cross Reference between AC 120-92 and
the SMS Framework
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
Page
SMS Implementation Guide - Appendix 8 – Cross reference between AC 120-
92 and the SMS Framework
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SMS Implementation Guide - Appendix 8 – Cross reference between AC 120-
92 and the SMS Framework
AC 120-92 (Appendix 1) SMS Framework, Revision 3 (6-1-2010)
6.6. Preventive/Corrective Action 3.1.9 Preventive/Corrective Action
6.7. Management Reviews 3.1.10 Management Review
6.8. Continual Improvement 3.3 Continual Improvement
7. Safety Promotion 4.0 Safety Promotion
7.1. Safety Culture 4.0 Safety Promotion
7.2. Communication and Awareness 4.2 Communication and Awareness
7.3. Personnel Requirements (Competence) 4.1.1 Personnel Requirements (Competence)
7.4. Training 4.1.2 Training
7.5. Safety Lessons Learned 3.3 Continual Improvement
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SMS Implementation Guide - Appendix 9 – Example Letter of
Appendix 9
Example Letter of Acknowledgement
To:
IMPLEMENTATION GUIDE
For:
Revision 3
June 1, 2010
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SMS Implementation Guide - Appendix 9 – Example Letter of
(Sample)
Letter of Acknowledgement
Safety Management System Pilot Project
Participation: Level [One, Two or Three]
This is to acknowledge the participation of [airline name] in the Federal Aviation Administration’s Safety
Management System (SMS) pilot projects. Based on our review of your company’s plans, documentation, and
activities, we have determined that your SMS project meets the expectations of the Flight Standards SMS
Framework and the SMS Pilot Project Implementation Guide for [Level One, Level 2 SMS, Level 3 SMS, etc.].
This achievement has been validated by representatives of your FAA Certificate Management Team and the
Flight Standards SMS Program Office.
The FAA currently does not have regulatory requirements for SMS but is considering SMS regulations. The
SMS Pilot Projects consist of voluntary implementation of SMS by operators and other aviation service
providers. The FAA Flight Standards SMS Framework used in these projects is based upon the requirements of
Order VS 8000.367, Appendix B and the SMS Framework specified by the International Civil Aviation
Organization in ICAO Annex 6 and further detailed in ICAO doc. 9859, Safety Management Manual.
The implementation process in the SMS Pilot Project Implementation Guide is based on a four phase process as
recommended by ICAO in ICAO document 9859 Safety Management Manual. Your company will be expected
to advance to the next level of SMS maturity within twelve months upon satisfactory completion of a program
review.
This assessment of your company’s achievements does not imply formal FAA acceptance or approval of your
SMS or its components but does recognize your active participation to this vital phase of development. We are
grateful for your contributions to the continued improvement of the U.S. level of safety.
/s/
John M, Allen,
Director,
Flight Standards Service
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